GDPR Art. 12 explicitly requires that privacy disclosures be provided in "clear and plain language" — dense legalese or unmodified boilerplate with unreplaced placeholders ([COMPANY NAME], [DATE]) does not satisfy this requirement. The FTC considers burying material terms in hard-to-read fine print a deceptive practice. Beyond regulatory risk, users who cannot understand what they are agreeing to are more likely to dispute charges, file complaints, and leave negative reviews. Unfilled template placeholders — "We retain data for [PERIOD]" — are evidence in regulatory investigations that the business deployed legal pages without review, which courts treat as bad faith.
High because GDPR Art. 12 requires plain-language privacy disclosures, and unmodified boilerplate with placeholders constitutes both a regulatory violation and evidence of bad faith in enforcement proceedings.
Search legal page source files for common placeholder strings before shipping and replace every instance with real values.
# Run this on your legal page content files
grep -r "\[COMPANY\|\[DATE\|INSERT_DATE\|COMPANY_NAME\|\[YOUR COMPANY\|\[PERIOD\" \
app/terms app/privacy app/refund-policy content/legal/
For readability, restructure dense paragraphs by adding descriptive <h2> subheadings for each section, breaking sentences at natural points, and adding a plain-language summary at the top of each page:
<section className="bg-muted rounded p-4 mb-8 text-sm">
<strong>Plain English summary</strong>
<ul>
<li>You keep ownership of content you create.</li>
<li>We can cancel accounts that violate these terms.</li>
<li>Disputes are resolved in Delaware courts under Delaware law.</li>
</ul>
<p className="mt-2 text-muted-foreground">This summary does not replace the full terms below.</p>
</section>
ID: legal-pages-compliance.content-clarity.plain-language
Severity: high
What to look for: Enumerate every relevant item. Read a representative sample of each legal page — at least the first 300 words and the section headings. Evaluate readability. Signals of poor readability: dense paragraphs with no subheadings, sentences exceeding 40 words, jargon-heavy terms without plain English equivalents ("hereinafter," "notwithstanding the foregoing," "indemnify and hold harmless" with no explanation), walls of text with no visual structure, legal boilerplate copy-pasted wholesale with company name placeholders still as "[COMPANY NAME]" or "INSERT_DATE." Signals of good readability: short sections with descriptive headings, plain language for key obligations ("You are responsible for keeping your password secure"), numbered or bulleted lists for complex items, and a summary or FAQ for the most important terms.
Pass criteria: At least 1 of the following conditions is met. Legal pages are written in language that a non-lawyer adult could read and understand the key points of their agreement. Headings are descriptive. Paragraphs are reasonably short. The most important user-facing rules (what you can and cannot do, what happens if you cancel, what data is collected) are stated clearly. No unfilled template placeholders.
Fail criteria: Legal pages consist of unmodified boilerplate with company name placeholders still present. Pages are dense walls of legalese with no structure. Key terms (what users are agreeing to, liability limits, dispute resolution) are buried in long paragraphs with no headings. Readability score would be at a postgraduate level.
Skip (N/A) when: No legal pages exist (this is already flagged by the existence checks above; skip this readability check if there are no pages to evaluate).
Detail on fail: Specify the issue clearly. Example: "Terms of Service contains '[COMPANY NAME]' and '[DATE]' placeholders throughout — template was never customized." or "All three legal pages are dense legalese blocks with no paragraph breaks or subheadings. No plain-language summary of key user obligations." or "Privacy Policy contains unfilled fields: 'We retain data for [PERIOD]' — retention period never specified.".
Remediation: Legal pages do not need to read like a novel, but they do need to be understandable. Apply these structural improvements without changing the legal substance:
Plain-language restructuring tips:
1. Add descriptive subheadings for each section
Before: a wall of text
After: "### Your Account Security" — "### What We Can't Do" — "### Cancellations"
2. Break long sentences at natural points
Before: "Notwithstanding the foregoing, in the event that any provision of these
Terms is determined by a court of competent jurisdiction to be invalid..."
After: "Some of these terms may not apply in your location. If a court finds
any part of these Terms unenforceable, the rest of the Terms still apply."
3. Replace template placeholders
Search for: [COMPANY], [YOUR COMPANY], [DATE], INSERT_DATE, COMPANY_NAME
These must all be replaced with real values before the page goes live.
4. Add a plain-language summary at the top
"What this means for you (plain English summary):
- You keep ownership of any content you create.
- We can cancel your account if you violate these terms.
- Disputes are resolved in [State] courts under [State] law."
(Note: summaries do not replace the full terms — they supplement them.)
Having a lawyer review the terms is still recommended. The goal here is readability, not legal drafting.